ML091940188

Unit 1 Supplement to WBN-TS-09-11, Proposed Change to TS 3.6.3, Containment Isolation Valves, Regarding Position Verification Requirements (TSTF-269-A, TSTF-45-A, and TSTF-440-A)

ML091940188
Person / Time
Site:	Watts Bar
Issue date:	07/10/2009
From:	Skaggs M Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME1435, TSTF-269-A, TSTF-440-A, TSTF-45-A, WBN-TS-09-11
Download: ML091940188 (3)

Text

July 10, 2009 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:

In the Matter of ) Docket No. 50-390 Tennessee Valley Authority )

WATTS BAR NUCLEAR PLANT (WBN) - UNIT 1 - SUPPLEMENT TO WBN-TS-09-11, PROPOSED CHANGE TO TS 3.6.3, CONTAINMENT ISOLATION VALVES, REGARDING POSITION VERIFICATION REQUIREMENTS (TSTF-269-A, TSTF-45-A, AND TSTF-440-A)

(TAC # ME1435)

On June 5, 2009, Tennessee Valley Authority (TVA) submitted, pursuant to 10 CFR 50.90, a request for a Technical Specification (TS) change (WBN-TS-09-11) to License NPF-90 for WBN Unit 1. The proposed amendment would provide alternatives for valve position verification in various Required Actions and Surveillance Requirements in TS 3.6.3, Containment Isolation Valves. The TS changes are based on TS Task Force (TSTF) change traveler TSTF-269-A Revision 2, TSTF-45-A Revision 2, and TSTF-440-A.

TVA discussed this change with the NRR Project Manager and Reviewer on June 26, 2009. In that discussion, TVA agreed to supplement the TS change request with a description of our locked valve program. This letter provides that description.

TVAs locked valve program is described in our Operations Department Procedure OPDP-6, Locked Valve/Breaker Program. This procedure identifies that Operations is responsible for implementation of the program and for resolving disagreements related to the program.

Engineering is responsible for identifying any design required locked valves/breakers.

OPDP-6 provides criteria to identify valves that should be locked, and specifies methods for locking. Locking devices should be fastened in a manner that resists movement, and may include crimp cable, chain and padlock/lock tab, wire-tie, valve cover/collar, plastic seal, wire locks, lead seals, mechanical restraining device, bolt, or similar devices depending on specific checklists.

U.S. Nuclear Regulatory Commission Page 2 July 10, 2009 OPDP-6 also specifies that safety-related valves/breakers listed in the site specific procedure/instruction will be verified locked at least once every refueling cycle. This periodic verification consists of a single person check that required locking devices are present and intact. Other approved plant procedures that specify more frequent verification may be used to satisfy these requirements, and periodic verification may be waived for valves located within a high radiation area or a highly contaminated area, valves located within a locked, covered, or controlled access area (provided access to the area has not occurred since the last documented verification). Reasons for not field verifying locked valves shall be documented on the relevant procedure/instruction documentation.

Administrative controls and operational restrictions are provided in OPDP-6 such that Shift Manager or Unit Supervisor permission is required to open locks under administrative control, and for repositioning of locked valves/breakers. Additionally, locked valves and breakers shall NOT be manipulated EXCEPT by approved procedure, clearance order, or temporary system alteration. Locked valves are verified in accordance with SPP-10.3, Independent Verification Program.

The locked valve program for WBN is well-established, provides robust controls, and is adequate to grant high assurance that valves are properly positioned to support the proposed technical specification change, WBN-TS-09-11.

There are no regulatory commitments associated with this submittal. If you have any questions concerning this matter, please call Michael Brandon, Site Licensing Manager, at (423) 365-1824.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 10th day of July 2009.

Sincerely, Original signed by Mike Skaggs Site Vice President Watts Bar Nuclear Plant cc: See Page 3

U.S. Nuclear Regulatory Commission Page 3 July 10, 2009 cc:

NRC Resident Inspector Watts Bar Nuclear Plant 1260 Nuclear Plant Road Spring City, Tennessee 37381 U.S. Nuclear Regulatory Commission Mr. John G. Lamb, Senior Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation MS O-8 H1A Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303